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REPUBLIC OF THE PHILIPPINES)
_________ +__ ) S.S.
AFFIDAVIT
In all I do. I will have-IDface my Creator to. W . hom I owe
my life and my being. In the depths of my nothingness,
His Holy Word becko I ed me to make a clean breast of
everything - "THE TRUTH WILL SET YOU FREE".
I, JANET LIM NAPOLES~Filipino, of legal age. and pr esently
confined at the Ospital ng Makati, after having been duly swor n to in
accor dancewith law, her eby deposeandstatethat:
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1. I amone of thj Respondents in OMB-C-C-13-0396, OMB-C-
C-13-0318,. OMB-C-C-13-0
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95
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OMB-C-C-13-0316, OMBC-C-13-0397,
~:-~~~C~~~~-~-~:-t~~~~~-::'-o~:'~:-~~~~:;~o~~~:~
C-C-~4-0018, OMB-C-C- 4;.0015, OMB-C-C-14-0~17, OMB-C-C-14-
0007, pMB-C-C-13-03 57 ar d my all other cases pending befor ethe Office
of the Ombudsman; for vio~ationof,R.A. No. 7080, as amended (other wise
known astheAnti-Plunder kct), for violation of RiA. No. 3019 as amended
(other wiseknown asAnti-Jaft andCor r upt Pr actices Act) andfor violation
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of Ar t. 1nof theRevisedRenal Code. .
.2. I am executing this affidavit to shed light on the facts and
cir cumstances sur r our tdin~the alleged Pr ior ity Development Allocation
Fund (PDAF) andMalampayaFund seams. This affidavit will alsotouch on
the use of gover nment fun~s likeinthe for mof budget inser tions andthose
cour s~d thr ough the Oep r tment of Tr anspor tation and Communication
(DOTC) and otHer tr ansac ions that 'I have per sonal knowledge of, but the
details of which lill.becoer ed byaJlother affidavit.
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3. I amlikewisepr esentinf this affidavit to suppor t my r equest for
the exclusion of my childr en James Chr lstopher Lim Napoles and Jo
Chr istine Napoles fr omtheabove~entioned Complaints. My childr enhad
no knowledge, par ticipation and ~volvementwhatsoever in the subject
cases. They had executed counter -akdavits to pr ove their innocence in the
char ges madeagainst them.
4. We ar e also willing r l1~lpthe gover nment by offer ing to
testify, based on our per sonal knowed~eandinfor mation, in all other cases
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that the Depar tment of Justice and theOffice of the Ombudsman may file
against thoseinvolved intheabove mentioned tr ansactions.
5.' Dur ingtheSenateInq ir yinNovember 2013, I optedto r emain
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silent because at that time, I was still at alossonwhat todo. Since, ldid not
have acounse~of my choice at thll Senate, I was ~en assisted ~y a lawy~r
fr omthe Pubhc Attor neys' Office (PAO) whomI Just met dur ing the said
inquir y. I wanted to' talk tothe Secr etar y of theDepar tment of Justice, Leila
De Lima, pr ior to my testimony i~the Senatebut var ious for ces pr evented
mefr om doing so, Thus. mysilenT intheSenateInquir y,
6. I became so car eful i,my dealings with other people because
oftentimes, I found them just fiJbing for infor mation for their per sonal
agenda. Sometimes, peoplewouldcometousoffer ing for helpbut endedup
extor ting huge amount of money, At var ious Instances, ther e seemto be
for ces who want to make me a"scapegoat" of the seams uncover ed by the
COA, anddiver t public' outr aget01ar ds:me. .
7. Sincethehospitalizat~onof my br other Reynald Limy Luy and
the filing of the Ser io~s Illegal geten~ion ca~e.against him and myself in
Mar ch 2013, my family and I itar te~ r eceiving thr eats fr om unknown
sour ces thr ough text messages using pr epaid cellular phone number s and
anonym,;,!",letter s, Our r ~nal Juor m~tion (telephone number s and email
addr esses) wer epostedon-lineendour agIngour detr actor s tohar m or thr eat
f
us. I I I fact, unmar ked vehicles 'and unidentified per sons wer e doing
sur veillance wor k at our house I dpffice, as well as in the r esidence of our
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, 8. While I was being detained at For t Sto. Domingo, and with the
sP~r itual guid~ce of Ar Chbish1psocr ates Villeg~, 0.0. ~d the other
pr iests who patiently and unceasr ngly pr ay and contmued pr aymg for me to
tell the tr uth, I r ealized that indeed I should TELL THE WHOLE TRUTH.
r elatives.
9. By telling the tr uth, which the people have been clamor ing and
I have been wanting to do for a long time, I intend to help my countr y and
wor k towar ds minimizing, if not totally er adicating cor r uption, so as not to
put to waste these r evelations.
10. Befor e under going sur ger y, God answer ed my pr ayer by giving
me the chance to talk to the Honor able Secr etar y of Justice, Leila De Lima.
And this bolster ed my belief tJat indeed, JELLING THE TRUTH will set
me fr ee.
11. Thus, 1amexecUli gth:saffidavit.
I AM NOT THE MOST GUlL Y AND NOT THE
"MASTERMIND" OF THE EGED 10 BILLION
PORK, BARREL SeAM NOR 0 THE. MALAMPAYA
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FUNDSCW
.12. I categor ically and str ongly DENY that I am the
"master mind" of the allege1dPr ior ity Development Assistance Fund
(P~AF) or Por k Bar r el an1 Mal~mpa:a Fund seam,s as well as other
pr ojects that usedgover nment r ds of which I haveper sonal knowledgeof.
13. Fir st and for emol I ani not capable anddo not have the "skill"
to r un such acomplicated scheme given my humble beginning. I amonly an
or dinar y pr ivate bUiinesswf. I neither havethepower nor the author ity
to or der the Depar tment of IBudget apd Management (DBM) to r elease
documents as well as command the. implementing agencies to choose an: 1-
foundation or Non-gover nr nen I Or ganization (NGO). Neither can I dir ect
nor contr ol any legislator to give me his or her PDAF and disbur se it as I
please. I also did not.conceptualize the for mation of NGOs as well as their
functions. I amnot and was fever an elected official nor an accountable
gover nment officer or employee. .
14. Second, the Pr ior ity Development Allocation Fund (PDAF)
existed even as ear lyas 1922. 1was not even bor n then nor my par ents. In
1~22, it was named.as the Piblic Wor ks Act. Even as ear ly as. 1925, the
misuse of the funds mthe for mof por k bar r el was alr eady questioned, The
PDAF, as known today, eVOlr edfr omMindanao Development Fund and
Visayas Development F.u~d.ir 1989, ~()untr ywid~Development Fund in
1990, then Congr ess Initiative All~catlon befor e It was called the PDAF
which we r efer to today. ~Ughit changed names over the year s, the
function anduseof thesaid 'Idhaver emainedthesame.
~~15. Thir d, the comiissio~ on Audit (COA) Repor t identifies at
least 82NGOs withanomalous or questionabletr ansactions for just theyear s
2007~~009.I amnot involvedInor familiar with all of theseNGOs. I didnot
cr eate nor for mall.theseNGfS such that one can conclude that I was the
"br ain" of using por k bar r r 1 or . foundations in tr ansacting with the
gover nmen~.I amabsolutely sr e that eve~befor e I enter edintothebu~in~ss
of tr ans.actmgthr ou.ghN?OSI or foundations, ther e wer e alr eady existing
foundations tr ansactmg withthegover nment,
General Background
of the Transactions
16. In my many year s of being a businesswoman, I engaged in
var iousbusinesses. Inoneor ty ve~tur es, I was theexclusive distr ibutor of
Nutr igr owth Philippines-a manufactur er of Liquid Foliar Fer tilizer s. After
a few year s, I
war able to buy ~utr igr owth Philippines and became a
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manufactur er of fer tilizer s. Later on, I decided to for mDr agon 1.5 Mega
Philippines after Nulr igr O~ toounler ed somepr oblems.
17. Ar ound 2000: I was intr oduced10 then Congr essman Flor encio
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Abad by Mr . Manuel Jar min. W e met at the Japanese Restaur ant in Edsa
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Shangr i-laPlazaHotel. In:that meeting, hetold meabout apr oject wor th 10
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million pesos. He showed-me he Special Allotment Release Or der (SARO)
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then explained to me wh~t it r as for . Befor e the meeting ended" I handed
him~hp 2 Million Pesos.:Whbr ntheN~ti~eof Cash Allocation (NCA) was
r eleased, I gave him another hp 2 MillionPesos. After war ds, when we
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talked about the implementation, he'askedmeif I hadanNGO. WhenI told
himI didnot haveanNG9' h1toldmehewouldtakecar eof it. Fr omwhat I
r ecall, heused Batanes El~ctr ~cCooper ativeto implement thepr oject. After
some time, he r etur ned the Php 4 Million Pesos I gave himwith an added
Php 2 Million Pesos mJr e. ~hat is when I star ted to tr ansact using the
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18. I wanted to ~xpr d my business as well as the distr ibution of
my goods~ustl~keany ot~er lusi~es~wom~n-, To my ~onfusionandsur pr ise,
the agencies did not tr ~sacl dir ectly Withcompanies. Instead, they had
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var ious NGOslFoundatio~s a their contr ol and disposal, whichthey offer ed
for r ent. Dennis Cunanan; wl's one of those who offer ed var ious NGOs for
r ent, which can be used t~i I plement pr ojects inlLRC. However ; I fear ed
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that these NGOs that th~y r ented".out had pr oblems as I hear d that the
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mcor por ator s t ey usear e.eit er ea or not existmg,
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19. NGOs- Du~to my fear , I wantedto makesur ethat theNGOs
B~R~eq~lr ements. "" s!W,y as f~as ~know, theNOOs ~amassociated
WIthstr icti:. complied w!th ihe ~eglstr atIOn.and other r equlfe~ents of the
law. Inadditiontothat, thF afenCIeshavestr ict r ules andr egulation astothe
accr editation of NpOs b~fo,e, they .en,ter into Memor andum of Agr eement
(MOA) with it. Thus, befor anNGO can tr ansact, the agency will have t:1-
PDAF.
inspect and accr edit the said GO. For such r easons, as far as I know the
NGO~I amassociated withaJe legal and not bogus as alleged ~d highly
publicized.
20. Theagents- Since1haveno capacity to knowthe pr ojects of
the agencies. as well as the funding of the legislator s, differ ent agents
r epr esenting the legislator s a~pr ba~h me and offer var ious pr ojects. The
agents ar e Ruby Tuazon, Ma~a Santos, Patr icia Gay Tan, Jen Cor puz and
Allan Ruste among other s. A~Iagents they r eceive an estimate of 5-10%of
the total pr oject cost as their commission. Thepr imar y r ole of the agents is
to followuptheagencies andlfgi~lator sfor thepr ocessingof thedocuments
aswell asther eleaseof thefunds.' Someof theagents ar enamedbelow:
a.. Ruby Tuazon-> I was intr oduced to Ruby Tuazon by his husband,
Car los Tuazon. ShehaI a lot of contacts in the gover nment because
she used to be the Socjal Se~r etar y of then Pr esident Estr ada. Since
then she would offer p.r ojec~~to me. Usually, she r eceives 10% to
15%commission.
b. ASEC Cather lne May C. Santos-I was intr oduced to Maya Santos
')when shewent tomy officetogether withher boyfr iend fr omcustoms
.named Jer r y Cailan. She intr oduced her self as the chief of staff of
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.Senator Manny Villar . She initially offer ed the PDAF of Senator
Legar da. She usually r ks for 10%commission while 40% will be
given to the Senator shetalked to. When shebecame the dir ector of
adminandfinanceof,e Dep~ent ~f Agr icultur e, ~e offer ed mor e
pr ojects to.me. Shewis ver y, influential mthe agencies because she
.was known ther e thus shewas theone who would always follow up
with the agencies. Shewould always boast about her connections as
she is also mar r ied to Ino Santos who is the son of then mayor of
Davao and slster -in-Iar of Bebot Bello, the for mer 0.0.1. Secr etar y
andJusticePi.ntonioNachur a, I
She usually gets her c mmission in cash. Though, at one time, I
r emember depositing 5 I hlion pesos in her Metr obank Jose Abad
Santos account. It was dur ing her tenur e as the dir ector at the
'Depar tment of Agr ar ij :Refor m when she was able to send her
:dau~hter to school in Lln10~' She was als~able to pur chase a lot of
vehicles and a newly onstr ucted house 10 AFPOVAI wher e she
,cur r ently lives in.
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c. Patr icia Gay Tan -1 as'i:intr oduced to Patr icia Gay Tan Alice
Villanueva and Lour des "Bab,y" Villanueva Reyes. She is the sister of
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Bibing Villacor ta and their br other Atty. Yaki Tan (for mer PLLO),
She is also the daughter ~flh';nCongr esswoman Agana ofBoho!. She
,_offer ed PDAF pr ojects and sold it to me. Accor ding to her , she has
,, been engaged in pr Ojecttl u~i~g PDAF funds for a long time. Later on,
{' I found out that she wo Id always enter into pr ojects that would tur n
, out to have pr oblems. I also found out that she would use the NGOs
associated with me, so I would be the one to have pr oblems. Dur ing
the fir st time they o,r ed to tr ansact, they showed me a SARO.
How~ver , the: SARO tur ed "" to be f~e.when I had it.ver ified. At
one time, she also Offjr ed a one (1) Billion wor th pr oject cour sed
thr ough DOTC using Fir st Allied United Enter pr ises. Luckily, I never
,pushed thr ough beca1se. after sometime I found out that they
pr oceeded wiiththe pr ojecf with so many ir r egular ities. She was also
, associated with ztAC' Rubber - Estate Cor por ation and
Pangkabuhayan Foundftion. I r emember that in the case of ZNAC
"Rubber Estate, COAfor d out that using Pangkabuhayan Foundation
and ther e was no deliver y.
d. Pauline Labayen-S1e is:~he chief of staff of Senator ' Jinggoy
Estr ada. As the chief of staff:of the Senator , the agents would always
, follow up with her r eg I ding ~her ocumentations. Eventually, she also
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.became theagent her self. s~e usually gets5%-10% commission inthe
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tr ansactions. Sheisalsotheiowner of tipsandtoes inGr eenhills.
e. Jennifer CO~PUZ-She ~!i~tr odUCedby Pauline "'?"She used
to wor k for Jinggoy Estr adathen for medaPR fir mat Or tigas, Sheis
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,ithe PR of Senator Sotto. r ballY, she gets 10% commission. "
:21. Leglslators=: The r .g~ntnegotiates the r ebate of the legislator s
as they haveagr eed or thelegislator would dir ectly demandhowmuchtheir
shar e should be. Whenever I ani. not amenable with their demands, they
would offer the pr oject to someone else. Ther efor e, the r ebate depends on
theamount thelegisllator or th1a~ent would demand. I r eally have nosay as"
to the amount, since if I don' agr ee, they would just offer the pr oject to
someone else. The r ebateused to' be just 20%, which later on became 30%
until 50% depending on what th~y demand. Aside fr omthat, the legislator
chooses which agency the fu n twill be cour sed thr ough.
:22. Agency- The legislator chooses which NOO he chooses to
par tner with to implement thd pr oject as shown by the endor sement letter
that they submit to the agen1Y' The agency will not r ecognize the NGO
unless the legislator endor ses ~er h. The agency enter s intoaMemor andum
of Agr eem~nl (~OA) with th1 NGO, and the legislator as 10the pr oject. The
agency ver ifies, Inspects and icc~ed!~tstheNOO befor ethey do so to make
sur e that the said 6r ganizatio~it t~gal and existing and compliant to the
agency's r equir ements and g idelines. The check is also r eleased via the
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agenc:, s cashier after the ~r ~~er "liquidation paper s ar e appr ~ved and
submitted. Some agency r eqr m,:s a, 3%-5% management fee as per the
agency r ules,
a. National Agr i BUliD~SS Cor por ation (NABCOR)"". Rhoda
Mendoza (owner of q~s Tr es Mar ias, which sells or ganic
fer tilizer oper ating .lS~. Mar ia Bulacan), Allan Javellana
h. Technology and Resour ee Center (TRCr r LRC) - Antonio
O D ". C l I h.--
r tiz, enms unant : - r
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'c. National Livelihood a1d'Development Cor por ation cNLDC) -
Alexis Sevilla :
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23. RebateICommiSSij',lgiven based Oil release of documents-
The givingof the r ebateof thelle~islator and commission of agent depends
on the whimof the agent andthd legislator . Whenthe agents or legislator s
appr oach me, they usually Shot ~e aphotocopy of the SARO or listing. At
that p~int, ther ebateof thele~isl~tor andtheagent is given either inpar tial
or in full. The photocopy of r hd SARO or listing shows that the pr oject
exists. When the or iginal of t~eJARO is r eleased by the DBM, sometimes
r ebate isalso giventothelegi~lattr whenwe.~r egivenacopy of theSARO.
Insomecases, uponr eleaseof lh~Noticeof CashAllocationbyDBM r ebate
is also given. Rebate:issometimes givenwhenthefmal check isr eleased by
theagency.
24. Release of Govermknt Funds- The MOAis enter ed into
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between the agency, legislator an~NGO. The agency r eleases the fund
appr opr iated for thepr oject upbfnsutmission of ther equir eddocuments. The
funds ar e r eleased in var ious r anches. Initially, fifteen (15%) of the fund,
themobilization fund, isr ele1ed sothat theNGO will beableto implement
the pr oject. Dur ing the ii.plementation of the pr oject, the agency
r epr esentative accompanies the1 NGO r epr esentative to make sur e the
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deliver y/implementation is m~de: They monitor the deliver y and
implementation. Thebeneficijr y yfthe pr oject will bepr ovided bytheLocal
Gover nment Unit (LGU), silce r he deliver y is done to their constituents.
Once the pr oject is. implemented and deliver ed, liquidation paper s will be
r equir ed by the agency, lhidh' the NGO complies with. In ever y
deliver y/implementation, the tllStFtor will give the appr oval if the funds
shouldber eleased dependingpnther epor t. Onlywhentheagency appr oves
the liquidation paper s submittled~iil they r elease the appr opr iate check for
35% ~r 85% of thepr oject co~t.If o~ly35% of thefundis initially r eleased,
the 50%of the bud~et will b~r eleased only upon submission of ter minal
r epor t r estating thedeliver y aI d jjoplenientation of thepr oject. All the fonn: ~
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a~ency ar e also pr ovided by the agency and
only filledupaccor dingtother tlS of thepr oject asimplemented.
25. Post- Audit- Onlr . tfter the fund is r eleased and the pr oject is
implementedwill theCOAconr tt theaudit. .
26. Computation of E.xAenses-The table below shows the usual
costing br eakdown of the pr oje~t, ~epending on the negotiation:
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As a busines
Legislator 40%-50%
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Agent 5%-10%
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Agency 2%-15%
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Pr oduction Cost I . 20%-35%
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Pr ofit and Op.:'r ation 5%-10%
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swoman, the ven tur e was pr ofitable since I get to keep 3% to
10% of the total pr oject appr opr iation, which IS shar ed with the NGO
pr esidents and oper ation COS+TO:as~ur ethat we get ~ comply with the
demands of the tr ade, we pr ocur e quahty goods and ser vices at ar easonable
pr ice. Thus, even if our pr odltiqn cost is limited to 20%-35% we ar e able
to comply with the pr oject 1quir ements without sacr ificing standar ds and
quality. We also aim for volume soI even if the pr ofit is small, I still find it
good business. In some cases, the pr oject is br eakeven. In some cases, I
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don't 'get to collect and ear n oni the pr oject. Those ar ejust par t of the r isk
of being abusinesswoman.
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THETRUTH~BpUTTHE~AMPAYAFUND
(OMB-C-C-13-0357, tll' GLORIA MACAPAGAL ARROYO)
27. Sometime m200
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4, ~et De Joya, Manag~r of Gentleman"s Club
locat,ed at t~e 40
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IFloo~of ~isC?ver y I.suites, went, to my office at the 25
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Floor of Discover y Suites together with Car los "Butch" Tuason, Ms. De
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Joya intr oduced me to Mr . tla~o~ as the cousin of then Fir st Gentleman
"FG" Ar r oyo, The~askedmetoIhr .~pthem, thr ough my sta~f,to fix~hecar
of Mr . Tuason, whichwasthed p~ked at thebasement par king, Dunng our
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meeting, Mr . Tuason told meth~t hewas in-char geof thepr ojects as well
asthePDAF of thenCong. Ig I ~oyo, br other of FGAr r oyo,
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,28. Few days after , I w~s invited by Mr . Tuason to the house of
~ar hou Ar r OYo:sister of FG r r yO, at theLaVistaSubdivisio~in Que~on
CIty, At that time, the housle~f Cong. Iggy Ar r oyo also m La Vlsta
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Subdivisionwas beingconstr ucted.
. 29. After the constr u~ti~nOf CongoIggy Ar r oyo's house, I was
again invited by Mr . Tuazol tf La Vista Subdivision. This time I was
intr oducedtoCongr essmaniofO.
30. Mr . Tuason told ~~ that he had a second wife named Ruby
Ch: Tuason. At that time'.tey v.;er eintr oublebecaus~hewas ~r iable.to
pr ovide her .monthly financlil suppor t for months. I did not believe him
.initially that he had financiaf pr o~lemwith his wife Ruby Chan Tuason,
because I knew himto be the cousin of FG and they came fr oma well-
knownwealthy family. The+aft~r :;he intr oducedmetoRuby ChanTuason
at the.latter 's house i~Bel-tir , :~~ati. While in Bel-Air , they fought on
financial matter evenmmypr esence.
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31. Mr . Tuasonthen ask~dRuby togivemegover nment pr ojects to
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be sour eed fr omthe PDAF. Hellikewise asked Ruby to shar e him in the
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r ebatewhich I wouldgive. i
32. Ruby then tol m+ that she had lots of contacts in the
gover nment because she used ~obe the Social Secr etar y of Pr esident
Estr ada and also because s le isjthe wife of FG Ar r oyo's cousin. At that
time, thepr esiden1wasFG's wiff' Glor iaMacapagal Ar r oyo.
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33. Ruby mentioned to Je that she also r efer s to Bobby Rodr iguez
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of Pangasinan some har d pr ojfcts sour ced fr om the PDAFs of some
senator s and congr essmen. i
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34. After that br ief mje~ing with Ruby at her house, she and Mr .
Tuason went to my office in Disr over y Suites offer ing to me the PDAFs of
some senator s and congr essmT ! '
35. Thus, it was in 20[4 ~hatRuby star ted to r efer to me the PDAFs
of la~m~ker s of ~hich she. afkfd ,to be paid 10% r ebate, aside fr o~. the
r ebate being pr omised and givenlto her by the lawmaker s, because that was
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also: the per centage that she :r e~eives fr om Bobby Rodr iguez. She
mentioned the names of patr idia Agana Tan and Alice Navales Villanueva.
She told me that the fO~ndati+!1 t~;,y wer e using had pr oblems, so she had
to r efer some of her pr ojects t me.r ,
36. I had sever al pr ~ects: with Ruby involving the PDAFs of
var ious lawmaker s.
i. 37. It was ar ound Nor ember 2009, when Ruby showed me the list
of gover nment funds amountr gto~Php 25 Billion fr om Malacanang, She
was then talking toa cer tain IMedy Poblador while explaining at the same
time the list of gover nment funds. I saw in the list the Php 5Billion Pesos
pr oject in the Depar tment ot Agr icultur e (DA), but she said she alr eady
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r e er r e It to anot er contr act r . :
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38. Ruby then r efer r ed to me the Php 900 Million Pesos
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gover nment fund, which wi ,I b+cour sed thr ough the DAR. She handed
over to me the SARO dated Ndvember 19, 2009. I was then r eluctant to
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accept the offer consider ing thelhuge amount, but she told me her "boss"
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named "RR" is aLittle DB
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39. She also told me th~t the funds will be r eleased immediately
because it would be used fJr i the 2010 Pr esidential Election of then
Pr esiden~Glor iaMacapagal ~o'.s political par ty. Shelikewise saidthat
shewas m-char ge of theTVatl~er tlsementsof theLakas Par ty. Sheasked
meto send my staff to theDMofficeandto call her should ther e be any
pr obleminOAR soshecouldda~lMedyPoblador tofixthepr oblem.
. 40. At that time, I 1nl lot know that the Php 900 Million Pesos
fundwas the Malampaya Fun~. E~en on r ecollection now, I don't think I
was 'dir ectly infor med that tHepr oject will be utilizing the Malampaya
. I
Fun~. We agr eed that 60% r er ~te or Php 540 Million Pesos would go to
her , 35%would be set asidefur !thepur chase of goods to bedeliver ed and
5%would beleft for thefoun~aiioll. Again, shesaidthat themoney would
I
beused for the20101 election. 1
, ,
- \, :
;
i
41. Inthat computatio ,~hefoundationwouldget 5%fr omthePhp
;
900Million Pesos or Php45MillionPesos.
,42. I agr eed to thj pr oposed 60% r ebate, consider ing our
ar r angements for thesaidpr oject. Shesaid, shewould choosetheLGU that
they wantedtousesinceitwill beelection. Shealsotook ther esponsibility
of pr ocessing the documents I [~asking the, signator ies to sign documents
which the DAR may r equir e, Y r esponsibility would be limited to the
deliver y of thegoods of the G~lEnd User . I only r equested her to choose
, i
LGUs fr omnear by towns d *ovinces to make sur e deliver y would be
I
easy.
,
! r ;
, 43. When the documentation pr ocess was star ted, Ruby Tuason
insisted to submit documents~v~ni.fitis still incompleteandto just submit
additional documents later . ~he\toldmenot towor r y because accor ding to
her Malacanang alr eady instnuct~dthe DAR to speed upthe r elease of the
check. I :
.1'
" I
, } ':
44. When thecheck w slr eleased by theDAR, I askedRuby about
theimplementation ofthedeliv~r Jy.iRUbYTuasonwastheonewhopr ovided
me the list of the ninety I ~ven (97) mayor s and their r espective
i
,! 45. I also asked Ruby *ho would pick up the 60% or Php 540
Million Pesos, she told me to bpng the money to her house in Zagu St.,
I
Dasmar inas Village, Makati Ci [which shewasthenr enting.
municipalities.
' I '
'46. Whenthemoney Jas deliver edtoRuby, I askedher thenames
of the coor dinator s in or der to ahange the deliver y of the goods. But she
saidshewouldjust get back tJ me.' Fewdays later , Ruby went to my office
asking for the35% or Php 31J
1
'illionor iginally intended for thepur chase
of the goods to be deliver ed t~the beneficiar ies. She told me that the
deliver ies should be:made in 'a~hinsteado.f goods to the Mayor s because
they wanted funds for their elebtioILcampaign.
47. At fir st, I r efused to r eleasethe said amount because I alr eady
used par t of the money to pay the,r aw mater ials needed for the deliver y.
Ruby insisted and toldme4t th~end user s would not accept the goods
evenin insistto deliver . I felf tr apf,edat that timebecausein don't givein
to her r equest, I won't beabl~to comply withtheliqui~ationr equir ements.
Thus, I was for ced to hand her the 35%because I did not want to have
pr oblems later on. After deli~[ler ih., g.themoney, shegavemethebeneficiar y
list for thepr oject. i
, '
: 48. Dur ing thetr ansati~n, whenever I r equestedRuby to followup
about the documentation of tte~r oject, I oftenhear her talking to acer tain
Medy Poblador tofollow-up.
,
!
i
49. Ar ound the per iod 9f the Php 900 Million Malamapaya Fund
300,000,000.00) wor th house i~Dasmar inas, Village along Mahogany
!
v , ,.
,
l
,
THE TRUTHr iOUT THE FILEDCASES
In OMB-C-C-13-0396 (FIO ,so~u1m
Ponce Enr ile, et.al.) and OMB-t-c-
13-0318 (NBI vs. Juan Ponc9E~le,
et.al.), the following tr an~ac~ions
occur r ed with the Office of :Seator
JuanPonceEnr ile("Sen. Enr ile" :
I : 1 T M'll' P
50. In SARO.# 07-046~8; the amount IS wenty 1 Ion esos
(Php2000000000) hi. J TLRC
Str eet.
, , . t eagency 1
; ' ,' ,
"I
! ;
: \
5I.
Thecomputationof dor timissionher einpr ovided.to wit:
~ .~' j
I
! Per centage Amount
,Juan Ponce Enr ile
r 5~lesstax
Php8, 640,000.00
':Ruby Tuazon
110%lesstax Php 1,920,000.00
',Antonio Or tiz 110%lesstax Php 1,920,000.00
Dennls Cunanan 15%lesstax Php 960,000.00
:
. 52. The advanced plyments given to Sen. Enr ile and Ruby wer e
madeupon listing. Thecommission .of Sen.'Enr ileandRuby wer epicked up
by Ruby in my office intheDiscover y Suites (Unit 2502). I r emember she
wor e ,ablack duster type dr ess accented with pashmina shoal. I per sonally
. handed the cash to Ruby +o~ting to. Ten Million Five Hundr ed Sixty
Thousand Pesos (Php 10,560,000.00). She asked that the cash for the
Senator Enr ilebeplaced injbo~(PI'P 8,640,000.00) whileher commission
beplaced inher bag(Php 1'1,000.00).
53. I per sonally met Dir ector Antonio Or tiz in Pancake House in
Malayan Building in Or tig+to ~ve him his commission of One Million
NineHundr ed Twenty Thousand ~Pr .-pll,920,000.00),hewaswear ing along f f
sleeveshir t andbr ownslac~san~~amear oundin ablack pickup. Dennis
' ,I
" -! : .I
l' i
,
,"
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I I '
Cunanan was met by my nephew! John Lim at the For d Showr oom in Edsa
Gr eenhilIs for his commission ot Nine Hundr ed and Sixty Thousand (Php
960,000.00). Both Or tiz and CunLIan's commission wer e 'given befor e they
would r elease the check to thJ fd~'dation since I was told that they would
not r eleasethecheck unlessthT ~: l gettheir commission fir st
,54. In SARO #ROCS-08-01347, the amount is Twenty Five
-I I '
Million Pesos (Php 25,000,000.00) and the agency is DA-NABCOR.
r 55. ,The computation pf commission is her ein pr ovided, t~' wit:
.,'
I
. Per centage Amount
Juan Ponce Enr ile 40% less tax Php 10,000,000.00
Ruby Tuazon : 15% less tax Php 3,750,000.00
!
'Allan Javellana
I
. 10% less tax Php 2,500,000.00
Rhoda Mendoza
I
: 5% less tax Php 1,250,000.00
,
" I " ffi' d "0 h
"56. Ruby Tuasor i went to my 0 ice an gave me a SAR ' wor t
Twe~ty Five Million Pesos (~hP 25,000,000.00) she told me that she will be
meeting with her co~tact in tte offic,e of Senator Enr ile later i~t~e day and
she needs to close this deal tj sell the SARO befor e that. She insisted that I
pr oduce the necessar y cash S0 she can r elax and not str ess about it anymor e.
Shetold~e that if I decline, ~ will bemeetingwithP~cia "Gay" Agana
Tan later mthe day to convjce he,r tjo pr ~duce the money mstead. I check~d
my finances and was able to come up with the amount. I placed the cash m
. . h
two separ ate bags and hande it to hbr .
57. I sent Rhoda JendJ and Dir . Allan lavellana's por tion to
their ~~ce thr uoneof mysr .v-thecashintwo separ atep,aper bags
containing Two Million Five Hundr ed Thousand Pesos (Php 2,500,000.00)
for Dir ector Javellana andOr e ~llion Two Hundr ed Fifty Thousand Pesos
(Php ,1,250,000.00) for Rhod Mendoza,
"
"
I
I .
'58. In SARO # ROCS-09-00804, the amount lS Twenty Five
, I I
" I
MillionPesos (Php 25,000,OOO,OQ)and the agency IS DA-NABCOR.
~59. Thecomputation~f lo~mission isher einpr ovided, t~wit:
I
:Per centage Amount
I
Juan Ponce Enr ile :45% less tax Php 11,250,000.00
:
Ruby Tuazon
I
' 10% less tax Php 2,500,000.00
Allan Javellana : 10% less tax , Php 2,500,000.00
Rhoda Mendoza ; 5% less tax Php 1,250,000.00
;
; ,
60. For this tr ansaction I met Ruby Tuason 10 the lobby of
Discover y Suites. She was tJget~er : with her dr iver and maid. I placed the
entir e amount of Thir teen r llion Seven Hundr ed Fifty Thousand in a
pr inter box to make it less cr ns~icuous. I sent, the por tion of the funds to
Dir ector Allan Javellana and ~o~aMendoza. I instr ucted one of my staff to
meet Rhoda Mendoza in the Star bucks at the Philippine Stock Exchange
Building in Or tigas and hanJed her ')two paper bags containing One Million
Two Hundr ed Fifty Thousmf (Ph~,;1,250,000.00) for Rhoda Mendoza and
Two Million Five Hundr ed ~ou~ar Pesos (Php 2,500,000.00) for Dir ector
::::~anaRhoda Mendoza gl' ave me a call when she r eceived both paper
' j' 61. In SARO #RO S-08.05216, the amount is Fifty Mi~ion Pesos
(Php
i
50,000,000.00) and the agency.isDA-NABCOR.
!
62. The computatio ~of commission is her ein pr ovided, to wit:
, Per centage Amount
Juan Ponce Enr ile 45% less tax Php 21,825,000.00
I "
Ruby Tuazon 1O~ less tax Php 4,850,000.00
I
,
Allan Javellana 10o/pless tax Php 4,850,000.00
: .
Rhoda Mendoza 5%iless tax Php 2,425,000.00
I
I I ,.
:
:
"
17
" ,
63. For this par ticulai t~~~ac~i~nRuby gave me a c~l1again.~he
toldmethat shewas abletoaC1.Ulfe ,~listing under Senator Ennle amountmg
toFifty Million Pesos (Php50,OOP,OOO.OO). Sheaskedmeif I was inter ested
andI' saidyes. Shetoldmeto give her acall onceI have gather ed the cash
for ther ebateandcommission. After 2 daysI gaveher acall andsaidthat it
was ';'ady for pickup inmy ~J .~. Rubysent her dr iver "AI" to ~ick it up. I
placed Senator Enr ile's advJcei comnussion m a box amountmg to Ten
Mi11i~nNine Hundr ed TwelJe lr h~usand and Five Hundr ed Pesos (Php
10,912,500.00) and Ruby TU+oJ'S'in apaper bag containing Two Million
Four Hundr ed Twenty Five ~ousand Pesos (Php 2, 425,000.00) and then
sealed it befor e I gave it to Al. I ,confir med withRuby by giving her a call
that "A.I"r eceived these.aled11 ox ~d pap.er bagbefo~eI sent himoff. Upon
r eleaseof the SARO, Ruby asked: me If I can bnng the balance of the
commission in her house in 857 Sagu St. Dasmar inias Village, Makati. I
handedRuby a sealed box W~thSenator Enr ile's commission amounting to
Ten ~illion Nine Hundr edTr e1ve ~housand andFiveH~dr ed Pesos.(~hp
10,91,2,500.00) and Ruby Tuason's.in apaper bag contauung Two Milhon
, ,I
Four .:HUndr ed Twenty Five Thousand Pesos (php 2,425,000.00). She
excused her self and placed the box and paper bag in her r oom and came
back tohavesnackswithme.
64. I gave the eo missions of Allan Javellana and Rhoda
Mendoza, both of NABCOR, per sonally in my office in 2502 Discover y
Suites upon clear ing of the Jheck that NABCOR issued to the foundation.
Rhodawas wear ingtheusual I officeattir eandwetalkedabout wher esheand
her family lived. Shehadahar dtimefigur ingout howtotakethecashback
to he~office but later on fJundi someone to pick her up fr om my office
, I ,.
lobby:, I gave her two par er ~ags, one was for Dir . Allan Javellana
containing Four Million Eight Hundr ed Fifty Thousand (Php 4,850,000.00)
and another for her amountiag t~Two Million Four Hundr ed and Twenty
, I ' .
FiveThousand (Php2,425,0 O.oq).\
:1
r !:
'.65. In SARO #ROCF-08-07211, the amount is Fifty Million Pesos
(Php 50,000,000.00); the agency is D,A-NABCOR .
.66. The computation pf commission is her ein pr ovided, to wit;
.!
I
. Per centage . Amou n t
' .~'
Juan Ponce Enr ile 45% f~sstax Php 21,825,000.00
I , ;
Ruby Tuazon
tOo/r l~ss tax
Php 4,850,000.00
. ;Allan Javellana iO% less tax Php 4,850,000.00
.. I ;
.Rhoda Mendoza $%[esstax Php 2,425,000,00
' . I ; .
; 67. The advance coliisi6n was picked up by Ruby Tuason in my
unit at Pacific Plaza. We had H Italk over lunch, I even gave her thr ee (3)
pieces of blouses that I got fr ~m ~apan because she liked the same one that I
was wear ing that day. I shor e~ her the cash and we counted it in my
bedr oom and I placed Senator Enr ile's cash in a color ful duffel bag (Ten
Million Nine Hundr ed TwJlve. Thousand Five Hundr ed Pesos - Php
10,912,500.00) and her s in ~s smaller shoulder bag (Two Million Four
Hundr ed Twenty Five Tholand - Php 2,425,000.00). When she left I
escor ted her to the lobby of olr r condominium with her and saw her boar d a
Toyota Car nr y.
68. Ruby called and r .aidthat her dr iver ~'AI" will go to my office in
2502 Discover y Suites to Pio1kup ~llebalance of the commission. She said
she will not go up to my offir e anymor e since she needed to r ush and meet
someone. Her dr iver , AI, 4ved ~d I handed him a sealed computer box
for the Senator containing Ten Million Nine Hundr ed Twelve Thousand
. . I .' .
Five Hundr ed Pesos (Php 10
1
,912,500.00) and a paper bag containing Two
Million Four Hundr ed Twenty Five-Thousand (Php 2,425,000.00) for Ruby.
Aftef; he leftI called Ruby a! dtold her how much was in the box and in the
paper : bag.
I . " I
69. . Rhoda Mendo I called and r equested for an advance payment
for thepr oject, eventhoughtlhedo~ents wer estill being pr ocessed, since f ' lI , , -
. lQ I f
accor ding to her she and her 110ssbadly needed the money. I placed the cash
in twR (2) separ ate paper bag, one for Dir . Javellana containing Four Million
Eigh~Hundr ed Fifty Thousand Pesos (Php 4,850,000.00) and another one
for Rhoda Mendoza containr g Two Million Four Hundr ed Twenty Five
. Thou~and Pesos (2,425,000.~O). After sealing the paper bags, I instr ucted
~ne qf ~y staff dr iver , John ~aymOnd De Asis, to meet Rho~a in Star ~UCkS
mTektite Tower . Rhoda r equested that she be met up ther e smce she didnot
want ~obr ing such abig amoJnt without avehicle.
r
, ,
' . ~
; 70. In SARO#09t4084: the ~mount is Twenty Five Million
Pesos (Php25,000,000.00) J the agency IS TLRC.
; 7\. The ~omputatio~ of commissionis her ein pr ovided, to wit:
I
Per centage Amount
Juan Ponce Enr ile
I
45% less tax Php 11, 250,000.00
Ruby Tuazon 10% less tax Php 2,500,000.00
Antonio Or tiz and 10% less tax Php 2,500,000.00
' "
Maya Santos
;.;:
,.
,
,;
Dennis Cunanan
I
5 ,0/ 0less tax
Php 1,250,000.00
: \ .
I . ' .
172. Ruby Tuason called me and told me to pr oduce the necessar y
amo~t for a PDAF pr Ojel
1
of Senator Juan Ponce Enr ileam~unting to
~t
Twenty Five Million Pesos. ' he was in a r ush and was ver y insisting I take
thep~oject and pr oduce the ioney as her other tr ansaction involving Senator
Enr ile's "har d" funds that sr e sold. to a cer tain Bobby Rodr iguez is being
tr oubfe~ome. She told me fhat ~~bbY Rodr igue.z is having .~har d time
pr oducing the agr eed amounl and mtur n puts her ina har d position because
she i~n~t able to deliver her end in Senator Enr lle's. o~ce. I agr eed and tOl~
her to give me a few days to put up the cash. She insisted that I pr oduce it
ASAP and gaveme two da+ to pr oducethe cash. After afew days, I gave
her a call and she. told me that she will send "AI" to pick up the cash in my
office. I placed Eleven Midion Two Hundr ed Fifty Thousand Pesos (Php
11,250,000.00) and Two ~i1lion.Five Hundr ed Thousand Pesos (php rI/ /
?O yr
" ~,
2,500~OOO.OO) intwo separ atebags andgavethebags to Al after confir ming
withRuby Tuasonthr uaphon~cald
73. T~ecashfor Dir er tor Or tiz andDennisCunanan was pickedup
by Ms. Cather ine Mae "Maya" Santos fr ommy office befor e the agency
r eleasedthecheck totheNGOl' '
74. In SARO #09-0r 952 ~heamount is Fifty Million Pesos (php
50,000,000.00) andtheagencyisNLDC. '
r ;
_.
75. Thecomputationof commissionisher einpr ovided, to wit:
I
Per centage Amount
JuanPonceEnr ile 15% lesstax Php21,375,000.00
,Ruby Tuazon to% lesstax Php 4,750,000.00
.Alexis Sevidal $%lesstax Php 2,375,000.00
I ..
76. Ruby Tuason tOl~me:~ send someoneto br ing the cashto her
house at 1857 Sagu st. Dasmar inas VillageMakati. Shetold meto givethe
full ahtount instead of the us6al 50% so she can ask for another pr oject as
soon} ,aspossible. She told me that she needed the money' befor e 5pm
n .
because shewill bemeetingjith A~. Lucila"Gigi" Reyes intheevening. I
br ought to her house (2) ~rduffel bags containing Twenty One Million
Thr ee Hundr ed Seventy FIV1Thousand Pesos (Php 21,375,000.00). I was
met by her dr iver "AI " outs~~eher .house, he told me that Ruby instr ucted.
himto wait for me:outside1d to get thebags. I handed over thebags to Al
thenI left. After afewminutes, I r eceivedacall fr omher andsheapologized
for not inviting me inbecaUll eshehad visitor s. After two weeks, sheagain
called meand insisted to get her commission andtold methat her dr iver Al
wouldpick it upandjust putl hecashinasea~edpaper bag. I placedthecash
amounting to Four Million even Hundr ed andFifty Thousand Pesos (Php
4,750,000.00) and met "AI" inthe lobby of Pacific Plaza. He used Ruby's
i
ToyotaCamr y.
/ .
-,
.:77. The money for Alexi~ Sevidal was deliver ed by my staff
Evel~de Loon i~the NLDC tffi~in One Cor por ate Plaza Ar naiz Avenue
Makati upon cleanng of the check issued by the GOCC. .
78. InSARO #09-o1%.Le amount is Sixty Million Pesos (pbp
-,
:
isNLDC. 0,000.00) and the agency
,
;;'79.
The computation I f commission is her ein pr ovided, to'wit:
I
Per centage Amount
,
"
Juan Ponce Enr ile 4r % less tax Php 25,650,000.00
Ruby Tuazon 1iO%less tax Php 5,700,000.00
AlexisSevidal 51%less tax Php 2,850,000.00
60,00
80. Upon instr uCti04 of Ruby, AI. her dr iver picked up a total
amount of Eighteen Million r ive Hundr ed Twenty Five Thousand Pesos
(Php 18, 525,000.010) in two separ ate sealed duffel bags, one containing
12,825,000.00 for Senator Enr ile and one containing Five Million Seven
. I ' .
Hundr ed Thousar tdPesos (Phr 5,700,000.00) for Ruby Tuazon. Dunng the
deliver y, Al br ought a tr ay of Palabok and BBQ for my staff. He was
wear ing a gr een shir t at tha~-time] Ruby insisted that I give her the full
com~ission in advance becaufe she,needed the cash for an investment. Then
after sometime, Ruby calledtr at she will be sending thr u fax a copy of the
SARO in my office. She ~lso tnsist1~t~have someone deliver th~bal~ce of
the cash for the Senator mhr houie 10 1857 Sagu St. Dasmannas VIllage
Makati, since her dr iver .is nr t ~vailable that day. To ~eed her r equests, I
asked my nephew John Lim to dr ive me to her house while on my way home
fr ome the office. I placed tJe cash amounting to Twelve Milljon Eight
.", I .
Hunqr ed Twenty Five Thousand (Php 12,825,000.00) in asealed duffel bag.
Upon r eaching her house IjUs~handed over the bag to her maid, but I did not
go inside her house.
~{81. The money for 'Alexi,~Sevidal was deliver ed by .my staff
Evelyn De Leon in his office at the NLDC at One Cor por ate Plaza Ar naiz
. ~ .
Avenue Makati, upon clear ing of the check issued by the GOCC.
f'
.82. SARO #G-09-0V112, .the amount is For ty Million Pesos (php
40,000,000.00) and the agency isNLDC.
83. The computation of co~mission is her ein pr ovided, to wit:
1 ' .
1
Per centage Amount
Juan Ponce Enr ile 15%less tax Php 17,100,000.00
Gigi Reyes 1%less tax Php 1,9QO,000.00
.Alexis Sevidal 5%less tax Php 1,900,000.00
I '
"84. Lucila "Gigi" Re~es C~led me and told me to br ing the cash to
meet up with her car in the back lobby of Discover y Suites. She told me to
put the cash in a sealed paper bag amounting to Eight Million Five Hundr ed
: ' ,
Fifty Thousand Pe80S (Php 8550,0'00.QO). She texted me to have my staff
,1
meet her in her car a gold Toyotal~~equoia SUVwith "7" plate number . I
placed the cash in a sealed paper bag as instr ucted and asked one of my staff
to b~~g it downstair s. Upon r eceiving a copy of the SARO, Lu~~la"Gigi"
Reyer told me to br ing the balance of the cash be br ought to her house in # 2
Yakan St., La Vista Village QC . She told me that she would give
instr uctions to the guar d in jhe gate to facilitate entr y and let my staff in
without leaving an identification car d at the gate. I placed the cash for
Senator Enr ile amounting. to Eight Million Five Hundr ed Fifty Thousand
Pesos (Php 8,550,000.00) in a sealed box and One Million Nine Hundr ed
.'
Thousand Pesos (Php 1,900,~00.00), in a sealed paper bag for Lucila "Gigi"
Reyes, I then asked my staff dr iver John Raymond De Asis to' br ing and
deliv~r the box and paper ball to h~r .r esidence in LaVista Village, Quezon
City.
, .
85. On ., other hand, the money 'for Alexis Sevidal (of NLDC)
was deliver ed by my staff EJ lynDeLeon in his office at theNLDC at One ( J j/ '
?i Yr
Cor por ate Plaza. Ar naiz Avelue Makati, upon clear ing of the check issued
by the GOC c. . .
In OMB.;.C-C-13-0395 (HO vs.
. I
Ramon "Bong" Revilla, et.al.) and
OMB-C-C-13-0316 (NBI vs.\Raman
"Bon~" Revilla, et.al.) The f~llowif!.g
tr ansactions occur r ed with the Office
of Senator Ramon "Bon g" ReviHa
("Sen. Revilla"):
..
, ,
""
86. In SARO #ROCS-O~~000949, the amount is Twenty Million
Pesos (php 20,000,000.00) an~the ~gency isNLDC,
~t
87. The computation of commission is her ein pr ovided, to wit:
I
Per centage Amount
; Sen. Revilla
t
o
%
Php 8,000,000.00
' .
:Richar d Cambe $%
. Php
1,000,000.00
,
\
(cos Sen. Revilla)
:Alexis Sevidal
r l."tax
Php 950,000.00
(NLDC)
. 88. I was invited f~lunc~by Senator Revilla in his r esidence in
114 Sar angani St., Ayala AI~bang Village, Muntinlupa. After eating, we
talked alone in the dining .i,and I handed him a paper bag containing
. cosh am~u~ting to Eigh.t Mi,on Pesos (php ~,ooo,ooo.OO)as full p.:ment
, for the hstmg. A~er a httle~Tall ta~, I left ~mce I had another meetm~ to
attend to. Atty RIchar d Cambe, who IS the Chief of Staff of Senator Revilla,
.. I .
" ,
per sonally br ought a copy of the SARO to my office in 2502 Discover y
Suites. I checked the docu,ent and asked my nephew to pr epar e One
Million Pesos (Php 1,000,000.00) t(> give to Atty. Cambe. My nephew got
the cash fr om my vault in my r ffiC~;'and seated th~cash in abr own envelope
and handed Itto Atty. Cambe who then excused himself to leave after war ds.
I
,;,
.,'
,
~;.
89. The, money for Alexis Sevidal was deliver ed by my staff
Evelyn De Leon in his offiJe at th~~NLDC at One Cor por ate Plaza Ar naiz
Avenue Makati, upon clear iJg of th6 check issued by the GOCC.
, I ,: ;
1.
90. In SARO # :ROCS-09-04973, the amount is Eighty Five
Million (Php 85,000,000.00) and the.agency is NLDC .
.I ,
~ ~ 'C-
" .'
i' 91. The (:omputatiop of commission is her ein pr ovided, to wit:
Per centage Amount
Sen. Revilla 40% Php 34,000,000.00
Richar d Cambe 5% Php 4,250,000.00
Alexis Sevidal 5% less tax Php 4,037,500.00
92. Senator Revilla told me that Atty. Cambe will pickup the cash
. .
in my office. I pr epar ed the cash and placed an amount of Seventeen Million
Pesos (Php 17,000,000.00) in a computer box and pr epar ed a paper bag
, containing Two Million 0leHundr ed Twenty Five Thousand Pesos (Php ,
2,125,000.00) for Atty Cambe. lper sonally gave the box and the paper bag
to Ar ty. Cambe and confir med with Senator Revilla over the phone befor e he
left. Upon the r elease of t~e SARb, Atty.Cambe called and infor med me
that he Wil,l br ing the COP1of .th~. SARO and th,at I ShOUld.pr epar ,e the
balan~e of the agr eement. 1agam 'iPr oceeded to put the cash m a box for
Senator Revilla amounting to Sevepteen Million Pesos (Php17,000,000.00)
andTwo Million OneHut Fitt: Thousand Pesos (pbp 2,150,000.00) in
ano~~r paper bag for Atty..f.ambe.: When Atty. Cambe ar r i~ed I gave him
theb;X andpaper bagconr g themoney andconfir medWIththesenator .
.93., The money f0
1
Alexis Sevidal was deliver ed by my staff
Evel;n De Leon to his office at the NLDC located at One Cor por ate Plaza
Amaiz Avenue Makati, upo [clear ing of the check issued by the GOCC.
~:
.94. In SARO #ROCS-09-04953, the amount is Fifty Million, and
the agency is NLDC.
95. The computatiop of commission is her ein pr ovided, to wit:
Per centage Amount
Sen. Revilla 40% Php 20,000,000.00
.Richar d Cambe 5% Php 2,500,000.00
.Alexis Sevidal 5% less tax Php 2,375,000.00
96. Atty. Cambe clued up and told me t~at he and the Senator
needed cash. He told me to bay in ftIUin advance for apr oject. I agr eed and
I
I met'him at UCC in the 26I str eet at the ~'For t Bonifacio" near McDonalds
in Global City. I placed c,sh of Twenty Million Pesos in two (2) sealed
small balikbayal1l. boxes ~or the,iSenator Two Million. Five Hundr ed
Thousand Pesos m a pape1 bag for Atty. Cambe. I left nght away after
giving the cash since Atty. Cambetinfor med me that he needed to r ush to
Ayala Alabang to meet Wit] Senator Revilla. After leaving, I called Senator
RevilJa to confir m that I ilr eady ~ave the cash to Atty. Camb~. Senator
Revilla in r etur n acknowledged the r eceipt of the cash via phone call,
:.97. The money 1Alexis Sevidal was deliver ed by my staff
Evelyn De Leon inhis 01e at theNLDC at One Cor por ate Plaza Ar naiz
Avenue Makati, upon clear ing of the check issued by the GOCC.
98. In SARO#RlcS-09-2357. the amount is For ty Million (Php
to wi
0,000) and the agency isNLOC.
,
~
99. The computati an of r ebate and commission is her ein pr ovided,
t:
,
--
I
Per centage Amount
.Sen. Revilla 40% Php 16,000,000.00
I
Richar d Cambe
I
5%
: I
Php 2,000,000.00
~: ;.
~ r
r:
?fi
Ji
,
40,00
"
Alexis Sevidal 15%less.tax Php 1,900,000.00'
100.
For ty. Million Pesos (Php 40,000,000.00). He told me that a pr evious
suppl~er backed out becauseit cann~t comply withtheir pr evious a~eement.
He asked me if I aminter ested or whether I could pay in full or else he
would givethebusiness elselher e, 'soI agr eed. After I agr eedtohis offer , I
pr epar ed SixteenMillionPekos(Php16,000,000.00) incashfor Sen. Revilla
, I ! l;
and Two Million Pesos (Phlil2,000~900.00)for Atty. Cambewhich I placed
inapr inter box I foundinth~offic~Ther eafter , I gavethesaidcashtoAtty.
Cambewhen hecameby mr office:topick it up and inr etur n handed me a
copy,of theSAROinexchange.
, '
" 101. Ontheother hand, themoney for Alexis Sevidal was' deliver ed
by my staff Evelyn De Leon in his office at theNLDC at One Cor por ate
Plaza Ar naiz Avenue M ati upon clear ing of the check issued by the
OOCC.
, ,102., In SARO # 1-09-070'65, the amount is Eighty Million (Php
80,OOp,OOO.OO) andtheager isNLDC.
103. TheIcomputati~nof commissionisher einpr ovided, towit:
Per centage Amount
Sen. Revilla 40% Php 32,000,000.00
;
Richar d Cambe 5% Php 4,000,000.00
Alexis Sevidal 5%lesstax Php 3,800,000.00
104. WhenAtty. ctbe Vi~t.~my officeto r eceive thecash as ~
agr eeduponr egar dingtheimplementation, hetoldmethat hewas expectmg
h 1
. I ,
anoter isting wor th P 80,000,000to ber eleased soon. He instr ucted meto
pr ep~e theamount ofSixtebn MillionPesos (Php16,000,000.OO)as advance
: , I \' "
payment. I was not pr epar ed to make the payment then thus it was only
,
,.. "
when he followed up after few a~~ewdays that I agr eed topay. The next
day he dr opped by my office again-and picked-up the agr eed amount and I
handed him the cash I pla~ in ,hox wor th Sixteen Million Pesos (php
16,0~0.000.~0) for Sen..Reyilla and One Million Pesos (Php 1,000,0~0.00)
for hlm, WhIChI placed Inah envelope. After war ds, I asked for mor e time to
" .
be able to comply with the r est of the advance for him because I was not
able to secur e enough funds fr om the bank. Atty. Cambe called up and
assur ed to me that he will ~ur ely get the SARO ther efor e I should pr epar e
the r est of the amount as Jdvance payment. The next day, he went to my
office to get the cash I placed in a box wor th Sixteen Million Pesos (Php
16,000,000.00) for senat1 Revilla and the Thr ee Million Pesos (php
3,000,000.00) to Atty. Cambe, which I handed to him in a paper bag. He
.\ .. . .
spent the whole after noon In my office that day because he had to wait for
the cashtober eleasedbytj bank. '. . .
105. The money for Alexis Sevidal was deliver ed by my staff
Evel)"l De Leon inhis o~be at th~NLDC at One Cor por ate Plaza Ar naiz
AvenueMakati uponclear i! of the,checkissuedbytheGOCC.
As r egar ds the cases, OMr .-C-C-r ~- .
0397 (FIO vs. Jose "Jinggoy" Ejer cito
Estr ada, et.al.) and OMB-C -C -: f3-
0313 (NBI vs. Jose "Jinggoy" Ejer eito
Estr ada,et.al.) The I following
tr ans,actions occur r e~ with ~he ?ffi.ce .
of Senator Jose "JInggOYll' EJer clto .
Estr ada ("Sen. Estr ada"):
.106. In SARO #R Cs.oJ01698, the amount involved is Twenty
Five Million Pesos (Php 25jOOO,000.00) and the agency isDA-NABCOR.
107. The computatien of commission is her ein pr ovided, to wit:
I
I
I
Per centage Amount
,
Sen. Estr ada 45% Php 12,500,000.00
, .
,
1)/
J r
."
-
Allan Javellana
10% Php 2,500,000.00
,.:;;1.
Rhoda Mendoza 5% Php 1,250,000.00
10% Php 2,500,000.00
,Ruby Tuazon
I '
108. Ruby Tuazon told me to accommodate a cash, advance wor th
Fifteen Million Pesos (php r s,ooo.ooo.OO) because she is-expecting to get a
pr oject "" fr om S~n. ESjada ..She su~ceeded in convincing me to accept
the pr oject because I twas Chr istmas time and that she badly needed the
'money. After I agr eed, she went t~my office and picked-up cash wor th
Twelve Million Five HunJed Thousand (Php 12,500,000.00) for Senator
; I \
Estr ada and Two Million ~ive Hundr ed Thousand (Php 2,500,000.00) for
her as her commission. I1 r emember she gave me fr uitcake then as a
Chr istmas gift and. s~ewas r er y gr a~eful that 1was. able to accommodate.her
r equest. I could vividly r elall that,t~~hewas weanng a ~ed dr ess that mght
b~ca4se she told me that s1e was g!;)ln~to attend a Chr istmas par ty. 1went
with her to the lobby as 1W[ also leaving the office then. 1r ode my car and
she was picked uipby avan
~l'
~~ .1
, '
: :
109. When the pr o~ect documents wer e pr ocessed at NABCOR,
Rhoda Mendoza, the assistt of Dir ector Allan Villanueva called me up and
told me that 1could get the check upon giving them the amount of Two
Million Five Hundr ed ThoJsand (Php 2,500,000.00) for Allan Javellana and
One Million Two Hundr ed Fifty Thousand (Php 1,250,000.00) for her self.
She picked up the cash i I my office at the 2502 Discover y Suites a day
befor e the check was r ele sed. 1per sonally gave the paper bag containing
the money to her .
110. In SARO # ROCS-08-01697 the amount is Twenty Five
Million Pesos (Php 25,~OO,OOO.OO) and the agency is DA-NABCOR.
111. The computation of commission is her ein pr ovided. to wit:
Rhoda Mendoza
Per centage Amount
Sen. Estr ada 45%
- Php 11,250',0'0'0'.0'0'
Php 2,50'0',0'0'0'.0'0'
. Ruby Tuazon
10'%
,Allan J avellana 10%
Php 2,50'0',0'0'0'.0'0'
I 5%:
Php 1,250',0'0'0'.0'0'
I r, . . .
. 112. Ruby appr oached me: and told me of an mcommg pr oject
amounting to Twenty Five+lIion~esos (Php 25,000,000.00). Shetold me .
that she needed her por tion amounting to Two Million Five Hundr ed
Thousand Pesos (Php 2,50'0'1,0'0'0'.0'0') because she needs the money ASAP.
She ~lso said she will be gltting the balance (Senator 's por tion)' upon the
r elease of the SARO amo*nting to Eleven Million Two Hundr ed Fifty
Thousand Pesos (Php 11, 2\50', 0'0'0',0'0'). Upon r elease of the SARO Ruby
called me and told me to r epar e the cash for the Senator amounting to
Eleven Million Two Hundied Fifty Thousand Pesos (Php 11,250',0'0'0'.0'0').
She told me that she would have: her dr iver pick it up in my office in
Discover y suites. Ruby's Jiver "AI " came and picked upthe cash that I
placed in apr inter box. Rhdda Mendoza went to my office in discover y and
picked up her 's and Dir er Or Javellana's por tion after the r elease and
clear ing of the check fr om their agency. . .
113 In SARO #jOCS-O~-03116' ~e amount is Twenty Million
Peso.
S(Php 20',0'0'0',0'0'0'.0'0')
and the agency is DA-NABCOR.
.1/ .
..
114. The comput tion of commission is her ein pr ovided, to wit:
1
Per centage Amount
I
Sen. Estr ada 30%
Php 6,0'0'0',0'0'0'.0'0'
~,
Ruby Tuazon
I
25%
Php 5,0'0'0',0'0'0'.0'0'
Allan Javellana
I
10'%
Php z.ooo.ooo.oo
Rhoda Mendoza
I
5%
Php 1,0'0'0',0'0'0'.0'0'
I
.1
0
, llS.Ruby went to I eandjbr ought me a SARO dated above. She
, . I ' -! '
told me that her buyer could not deliver on their agr eed payment since the
buyer still has a balance on lapr evious "HARD" SARO that they went into
business with. s~e told me r spii~Jhe cash senator and her this way since
the s~nator pr omised her an ear ly bir thday cash pr esent .
-,
. 116. Rhoda Mendoza picked up her s and Dir . Javellanas por tion
fr ommy office in two '"Pr te paper bags containing One Million Pesos
(Php 1,000,000.00) and Two Million Pesos (Php 2,000,000.00) r espectively.
117. In SARO #Ro.1 C8-0S-06025, theamount isFor ty Two Million
I
' " ,
, "
Pesos (Php 42,000,000.00) and the agency is DA-NABCOR.
118. The computation of commission is her ein pr ovided, to wit:
I '
; Per centage Amount
Sen. Estr ada
I
4?% Php 18,900,000.00
,
Ruby Tuazon 10% Php 4,200,000.00
,
Allan Javellana
I
10% Php 4,200,000.00
Rhoda Mendoza
5;%
Php 2,100,000.00
'"l
' f
,t 119.
' "
I was invitee by Ruby
in
her r ented house in Zagu St.
mar inas Village. While having lunch she showed me a listing amounting
.
Das
to For ty Two Million Pesos (Php 42,000,000.00). She Insisted that she
mak~S an advance of Fi+ Million Pesos (php 5,000,000.00) befor e she
agr ees to give me the pr oject. I told her that I was not liquid that time and
she r eplied that if that waJ the case: she would give the pr oject to someone
else. I left her ~ouseIhe+fter and never hear d of the pr oject again until
after sometime. Ruby caller me and told me that she has an available SARO
amounting to For ty Two ~illion Pesos (Php 42,000,000.00). She insisted
that I pay the full amount Jpfr ont befor e 1could give me the funds. Since the
SARO is alr ead;- availabl11 agr eed. She instr ucted meto pr epar e the cash
the next day and give her r call if ~~savailable and r eady for pickup in my
office alr eady. I placed the senator 's por tion amountingto Eighteen Mjl~
Nine Hundr ed Thousand Pesos (Php 18,900,000.00) and her s Four Million
, I
Two Hundr ed Thousand Pesos (Php4,200,000.00) in two separ ate bags. I
gave her acall that thecash is available and shetold methat shewill send
her dr iver "AI" to pick it up. Upon Al's ar r ival I gave her a call and
confir med that "AI" was inmy offic~andI gavethebagstohimalr eady.
-'
- .
120. Upon clear ing of the check Rhoda Mendoza picked up her 's
and dir ector Javellana's pohion aclounting-to Two Million One Hundr ed
Tho~~and Pesos (Php 2,+0,000.00) and ~our Million TWO,Hundr ~d
Thousand Pesos (Php 4,200,000.00) r espectively, I placed the cash m
, I '
separ atepaper bagsand gaveittoRhodor aMendoza.
. ..121. In SARO # IOCS-O~-0276~' the amount is Thir ty Million
Pesos (php 30,000,ooo.00)'nd theagencyIS NLDC.
: 122. The,oomputatlofcommission isher einpr ovided,to wit:
"I I '
lo': ,
I
-,
, Per centage Amount
Sen. Jinggoy
I
45% Php 13,500,000.00
Ruby Tuason I 10% Php 3,000,000.00 -
Alexis Sevidal I 5%lesstax Php 1,425,000.00
123. Ruby Tuasonlent to myofficeandgavemeacopy of. SARO
wor thThir ty MillionPesos (Php30~,000,000.00).Shetoldmethat shewon't
be needing an advanceuntil the check is clear ed fr omthe agency. I asked
why she's only telling me~bout this SAROnow. Shetold methat shewas
supposedto sell thePDAFlto Patr icia"Gay" AganaTanbut they ar ehaving
pr obl~ms with Patr icia "~ay" Agana Tan -not deliver ing goods in their
pr evious engagements. Shi fur ther said that pr ojects inZREC amounting to
Twenty Nine ~illion anti For ty Eight Million Pesos have, been ver y
tr oublesome. I I later on r emember ed the tr ansactions when the said
tr ansaction camel out inthi newspaper s sometimeFeb~ar y 2013.When the
check was r eleased, she told me to have the cash deliver ed to her r ented
home in Zagu St, Das bnas \1illage. I placed Thir teen Million 1-
.Hundr ed Thousand .pesos (,hp 13,500,000.00) and Thr ee Million pes~s
(Php 3,000,000.00) In two separ ate .duffle bags and dr opped of the bags m
I . I ;.
her r ented home in Zagu St. IDasr har inas Village on my way. home fr om the .
office that day.
ft;
124. The money for Alex~~Sevidal was deliver ed by my staff
~ ~, .
Evelyn De Leon in his offic, at the NLDC at One Cor por ate Plaza Ar naiz
Avenue Makati, upon clear ing of the check issued by the GOCC.
\125. In SARO #Rlcs-09-02770. the amount is N~e Million
, I .
~i -' .
Seven Hundr ed Thousand Pesos (Php 9,700,000.00) and the agency is DA-
NABCOR. . .
126. ThecomputatilOfcommission is her ein pr ovided, to wit:
Per centage Amount
Sen. Estr ada 45% : Php 4,365,000.00
;
Ruby Tuazon 10% :' Php 970,000.00
Allan Javellana 10% Php 970,000.00
Rhoda Mendoza 5%
-.
Php 485,000.00
I
.( 127. Ruby Tuazon called me to let me know that her dr iver "AI" was
on his way to my office. ACfor dingly, he had with him a copy of a SARO
with. an amount I of Nine Mil~~on ~even Hundr e~ Thousand (php
9,700,000.00). She told mel that~he dnver would wait for the advance
payments for the said SARp. That moment, I told her that I don't have
available money for the pr oj~ct but will have it by the next day. So, the next
day befor e I went to my offiJe, I passed by Tuazon's house at 1857 Sagu St.
DaS~ar inas, Makati in or de~to give her a black bag of cash ~or th Four
Milli~n Thr ee Hu~dr ed Six~ Five Thousand (Php 4,365,000.00) for .Sen,
. I -, .
Estr ada and Nine IHundr ed Seventy Thousand Pesos (Php 970,000.00) for
Ruby, Tuazon. Her maid r eJeived the
l
cash on her behalf; After her maid
r eceived the bag with cash, I left her house for wor k. After a few hour s, G--
, 11~ .
' .
Ruby Tuazon called me up to confir m that she has r eceived the bag with the
cash.:
';~128. Rhoda Mendoza
r
on t~e other hand, r eceived in my office the
cash Intended for Allan Jave~lana and her shar e. She also instr ucted me to
put the cash in two separ ati paper bags-one paper bag containing Nine
Hund~ed Seventy Thousand lesos (Php 970,000.00) for Allan Javellana and
Four hundr ed Eighty Five Thousand Pesos (php 485,000.00) for her self. She
picked up the paper bag in m~offic~and Lper sonally gave it to her .
129. In SARO #ROfS-09!-01612, the amount is Nineteen Million
Four H d d Th d P (Ph 19 40000000) d h .
NLD
un r e ousan esos p , , . an t e agency IS
.
C.
..
:
: 130. The computatior of commission is her ein pr ovided, to wit:
:
I
Per centage Amount
Sen. Estr ada 50% Php 9,700,000.00
.,
Ruby Tuazon 10% ' ! ;, Php 1,940,000.00
, Alexis Sevidal
\5%
d
i
: Php 921,500.00
:
j
131. Ruby Tuazon c~l1edme and told me that her dr iver IS alr eady
on his way to my r esidence to hand me an envelope with a copy of a SARO
; I '
'inside wor th Nineteen r illion Four Hundr ed Thousand Pesos
(l9,4PO,OOO.OO)under Senatfr Es~.'s PDAF. I called her up to confir m
that I alr eady r eceived the envelope with SARO but told her that I don't
have the funds to commit at I
fat
moment and fur ther advised her to call me
after two (2) days. After two (2) days, she called me again and insisted that I
commit the funds. In r etur n, told her that I have alr eady pr epar ed the cash
needed in my office in Or ti
1
as. After which, her dr iver Al pick it up so I
handed h.isdr iver a black bag with c. ash wor th Nine Million Seven Hundr ed
I !
Thousand Pesos (l~hp 9,700'fOO.oO) intended for Senator Estr ada and One
Million Nine Hundr ed and For ty Th9usand Pesos (Php 1,940,000.00) for
r
Ruby, Tuazon as her comr nission, I also pr ovided her a list of the br eakdown
r
~ U
, \
t.
.
"
..' ,
in the bag. Later , I r eceived a phone call fr om Ruby confir ming her r eceipt
of the cash.
. l32 .. However , the money intended for Alexis Sevidal was
per so~ally deliver ed by my s~aff Evelyn De ~eon to his office at the NLDC
located at One Cor por ate Plaza, Ar naiz Avenue Makati, upon clear ing of the
' j
chec~issued by the GOC
' I . \ .
133. In SARO #G
1
09-07076, the amount is Thir ty One Million
Pesos (Php 31,000,000.00) and the agency isNLDC.
134. The computatil of the' commission is her ein pr ovided, to wit:
,~~,
Per centage Amount
Sen. Estr ada
\55%
Php 17,050,000.00
Pauline Labayen
1
5
%
Php 1,550,000.00
Alexis Sevidal
1
5
%
Php 1,472,500.00
,t
'; \: .
: l35. Pauline Labayen, who-is a staff of Senator Estr ada went to my
office to infor m me that thet ar e expecting funds wor th Thir ty One Million
Pesos (Php 31,000,000.00) io be r eleased in their favor . She asked for fifty
five per cent (55%) for senatr Estr ada and five (5%) r elated commission for
her . I gave her Eight Million Five Hundr ed Twenty Five Thousand Pesos
(Php 8,525,000.00) for Sebator Estr ada and Eight Hundr ed Fifty Two
I . .
ThousandFive Hundr ed Pesos (Php 852,500.00) for her . She r equested me
to place the Senator ' s money to be placed in a box and to put her s in abag.
She was in ar ush to leave because she needed to go back to the Senate. That
time; she asked her dr iver 1go to the lobby and car r y the box so they could
leave' immediately. When t~e SAR? was r eleased, Pauline ~et with me to
hand over a copy of the SARO. She asked for the r est of their shar e, thus I
handed her a r ed r ag with Jash wo,r th Eight Million Five Hundr ed Twenty
Five Thousand Pesos (Php 8,S2S~OOO.00)for Senator Estr ada and .Eight
. Hundr ed Fifty Tio Thous d Fiv~:Hundr ed Pesos (Php 852,500.00) is for
her . ~
.i
I
\
.' . . '
. 136. The money for Alexis Sevidal was deliver ed by my staff
Evelyn De Leon in his office at. the, NLDC at One Cor por ate Plaza Ar naiz
Avenue Makati, upon clear ing of the check issued by the GOCC.
~' .
; 137 In SARO # G-09-07g~9, the amount is Fifty Million Pesos
(Php 50,000,000.00), and the gency isNLDC.
,
.~
,138.
The computation of commission is her ein pr ovided, to wit:
I
Per centage Amount
Sen. Estr ada
f5%
Php 27,500,000.00
Pauline Labayen
P%
Php 2,500,000.00
Alexis Sevidal p% Php 2,375,000.00
139. Pauline Labayer invited me to dine with her at L' Oper a at the
For t str ip in Bonifacio Global City. Dur ing the dinner , she showed me a
SARO wor th50,000,000. S+ gavetheter ms of 60"10, br oken down as 55%
for Senator Estr ada and 5% for her . She also insisted that the full payment be
give~at once sincethe S10 was al~dY r eleased. I IOI~her I will think
abOU~j It. After . a wee~, she lsked nl.eIf I was r ~ady to dehver the C~Shshe
pr oposed. After I said yes, she told me to dehver the same at "TIPS and
Toes", Wilson St. Gr eenhil s, which she owned. I placed the cash in two
small sized balik'r yan b01' whic:~contained Twenty Seven Million Five
Hundr ed Thousand Pesos fh
P
21,~500,OOO.00) for the Senator and Two
Million Five Hundr ed Th~usand fesos (Php 2,500,000.00) for her and
pr oceededto her par lor . Whr n I got ther e, she met me outside the par lor and
she tr ansfer r ed the box fr 01my car to the tr unk of her car . I r emember she
had per sonalized plates in her car .'
. 140. The money for Alexis Sevidal was deliver ed by my staff
Evelyn De Leon in his 0+ at theNLDC at One Cor por ate Plaza Ar naiz
Avenue Makati, ~pon clear i gof the check issued by the OOCC.
; I
l.
\141. In SARO #F-09 09580, the agency is NLDC, and the amount
is TWenty Four Million Twr Hu~dr ed Fifty Thousand Pesos (Php 24.
250;000.00) and the agency isNLDC
142. The computation rfcommission is her ein pr ovided, to wit:
I
Per centage Amount
Sen. Estr ada
~5%
Php 13,337,500.00
Pauline Labayen ~% Php 500.000.00
I
Alexis Sevidal ~%after tax Php 1,151,875.00
J
143. Aweek after I ~et Pauhne Labayen mGr eenhills, I r eceived a
call fr om her again. She told be that Senator Estr ada wanted to talk to me,
and I'did. Dur ing our =he told me that he is expecting apr Oject.
wor th Twenty Four Million Two Hundr ed Fifty Thousand Pesos (php
24,25?,000.00) and offer edt,e pr oj~ct to me. He instr ucted me to br ing the
agr eed amount at his office at #82 Et, Ar tiaga San Juan the next evening so
we could also meet mein r o~, The next night, I pr epar edThir teen
Million Thr ee Hundr ed Thij' Seven Thousand Five Hundr ed Pesos (Php
13,337,500.00), the: amount hr insisted, and placed it in abox. I went to his
office as he instr ucted and let the Senator Estr ada in per son for the fir st
time.!When I handed the box to him, he instr ucted one of his staff to put it in
his office at the gr ound floor . I did not stay long in his office because I was
tir ed that day. I .
I
144. The money for Alexis Sevidal was deliver ed by my staff
Evelyn De Leon id his offiCi at the NLDC at One Cor por ate Plaza Ar naiz
I .
Avenue Makati, upon clear ing of the check issued by the OOCC.
145. In SAr O #F-~9-09579' theamountis TwentyFiveMillion
Pesos (php 25,000,000.00) and the agency is !'lLDC.
j146. The computation of cor r mfssion is her ein pr ovided, to wit:
Amount
Sen. Estr ada 5~% Php 13,750,000.00
Percentage
PaulineLabayen 5% . Php 1,250,000.00
I
Alexis Sevidal 5to after tax Php 1,187,500.00
147. Pauline Labayen tailed meto infor mme that SARO # F-09
09580 was alr eady r eleased. r en she offer ed me another pr oject wor th
Twenty FiveMillion Pesos (Php25~000,000.00). Shetoldmeto pr epar ethe
I .,
cashthenext day so shecanbr ingthecopies of theSARO. Shewent to my
offic~the next day. I gave [her lihir teen Million Seven Hundr ed Fifty
Thousand Pesos (Php 13,750,~OO.OO)for Senator Estr ada and OneMillion
Two lIundr ed Fifty Thousandl~esos (Php 1,250,000.00) fo~Pauline ser ving
asher commission. Shealsoasked(or abonus for theear lier pr oject. Thus, I
gave; her an addititnal FiV~Hundr ed Thousand Pesos (Php 500,000.00)
which I placed inar ag toge er withher shar efor thenewpr oject. I placed
thecashfor theSenator inac mputer box.
I .
148. The money for Alexis Sevidal was deliver ed by my staff
Evelyn De Leon in his office at theNLDC at One Cor por ate Plaza Ar naiz
AvenueMakati, after thec1etg of thecheck issuedby theGOCC.
149. Basedr n my r ecollection, thetr ansactions atDAZREC by Sen.
Estr ada was tr anr cted b~ Rur Tuazon using a differ ent set of
NOOs/Supplier s (PangkabuhayanFoundation Inc.lPatr icia Agana Tan).
Ruby insisted for J higher plr cent~ge of commission, but I cannot comply
. I .,.
with her ter ms, othtr wise thedeliver y will suffer , because accor ding to her ,
sheknows someonF elsethat offer ~:abetter commission. This is one of the
r easons whywepar tedways. r
: I "~I
J
' ! ! .!
I -
.'
In OMB-C-C-14-0015, O~-C-C-
14-0016(FIOvs. Samuel M. pang'\"(a
et.al.) and OMB-C-C";13-03~5(NBI
vs. Samuel M. Dangwa, et.al.) 'qie
following tr ansactions occun\ed with
the Office of Congr essman I Samuel
M. Dangwa ("Cong. Dangwa'r : '.
. ':150. As far as 1c r e~eniber Car los Lozada, the staff of
conJ.,sman Samuel D~ would initiate the tr ansactions with me and
offer .their PDAF. The ter ms he gave wer e fifty per cent (50%) for
Congr essman Samuel Dangw~ and five per cent (5%) for himse1fand Er win
Dangwa. The pr oceeds in ten d ed for . the congr essman and agents ar e usually
picked up either in our office in Discover y Suites. 8tar bucks in Podium or
br ou~t to the office of the II\giSlat~r by one of my staff. Car los Lozada or
Er win Dangwa wer e usually the ones who r eceives the cash and usually
placed. in separ ate paper bag
l
; The; por tion for the funds intended for the
implementing agency is usually deliver ed to the per son in the agency after
en-cashing the cheek iSSUed~y the agency. .On occasion por tions intended
for Antonio Or tiz, 4ennis c.,i ail. an'::.A. llan Javellana and Rhoda Mendoza ar e
demanded by them befor e the r elease the check to the NGO.
- \-
. I . .. .
: 151. In SARO #ROGS-09-01612, the amount is Nine Million Pesos
(Php 9.000,000.00) and the aJencYb NLDC.
' --j
: ~
.152. The cOFPutation of the; commission is her ein pr ovided. to wit:
I I
Per centage Amount
i CongoDangwa 50% Php 4.275.000.00
; Car los Lozada/Er win 5% Php 427.500.00
! Dangwa \
"
Alexis Sevid,l 5% after tax Php 427,500.00
153. Car los Lozada,
\
staff of Congr essman Dangwa, went to my
office offer ing me J pr oject JOr th 9.000.000. He infor med me that it will be
implemented at NLDC. He :ave me. Ibe ter ms of ~O"/ofor con gressm~
. ~
I ., ..
.)
Dangwa and 5% for himself. They next day I asked my staff, Evelyn De
Leon, to meet the son of Congr essman Dangwa, Er win Dangwa, in
Star bucks, Podium to hand imthe money. The cash was placed in two
separ ate paper bags, one for the Congr essman wor th Four Million Two
Hundr ed Seventy Five Thousand P~sos (Php 4,275,000.00) and another for
Car lo~Lozada amounting to Four hundr ed Twenty Seven Thousand and
FiveHundr edPesos (Php427'100.00). .
154. Themoney for 1exiS Sevidal againwas deliver ed by my staff
Evelyn De Leon in his office\at theNLDC at One Cor por ate Plaza Amaiz
AvenueMakati, after theclear ingof thecheck issuedbytheGOCC. .
. 155. For tr ansactions with Congr essman Samuel Dangwa. The
computation of thecommissiouish~teinpr ovided, towit:
1
.~'
~
r.
. '
' .
CARLOS ALEX IS ANTONIO
DENNIS
ALLAN
RHODA I ~: H "~
SAMUEL WZADAI SEVIDAL-~"': ORTIZlMAYA JAVELLANA
! SARONo. Date Amo~nt . Agency
DANGWAsaGIo ERWIN (NLDC) 5% SANTOS (TRC)
CUNANAN
(NABCOR)
MENDOZA
i
DANGWA5% AFTER TAX 10%
(TRC) 5%
10%
(NABCOR)5%
j
ROCS-07-09157 11/6/07 8,000,000 TRC 4,000,000.00 400,000.00 800,000.00 400,000.00
ROCS-08-03249 4/ 14/ 08 8,000,000 NABCOR 4,000,000.00 400,000.00 800,000.00 400,000.00
ROCS-08-09584 --:-1213108- 8~OOO;OOO- ---NAB0R-
-4,000,000.00
Af\Jl nnn nn
800,000.00 400,000:00 -rvv,vvv.uu
~
G-09-08134 11/6/09 9,000,000 NLDC 4,500,000.00 450,000.00 427,500.00
r:
100,000_00
.'
ROCS-07-02040 2 1 1 1 0 7 1,000,000 TRC 500,000.00 50,000.00 50,000.00 ~
,
--.ROGs-0H3JilL
---.2L1.3Lllt
I 0 Qlill,000 TRC 5,000,000.00 500,000.00 1,000,000.00 500,000.00
!
~
Not
'.
.ROCS-01-091S-7 6,400,000 TRC 3,200,000.00 320,000.00 640,000.00 320,000.00
l
indicated c
.' . :J:;:;':.::,~.., . _ . :",:.:.~;\ .:.~ i 0' H ,
,
ROCS-08-03249 7/22/08 6,984,000 NABCOR 3,492,000.00 349,200.00 698,400.00 349,200.00
.,
f
ROCS-08-09584 5127/09 1,164,000 NABCOR 582,000.00 58,200.00 116,400.00 58,200.00
f.
,.
ROCS -08-09584 6/8/09 6,596,000 NABCOR 3,298,000.00 329,800.00 659,600.00 329,800.00
I
"
G-09-08134 2/10/10 .2,700,000 NLDC 1,350,000.00 135,000.00 128,250.00
,
i
2 1 2 3 1 1 0 4,500;000 NLDC 2,250,000.00 225,000.00 213,750.00
,
p
2-
4123/10 1,800,000 NLDC 900,000.00 90,000.00 85,500.00
,
(
Not
I
ROCS-07-02040 9,200,000 TRC 4,600,000.00 460,000.00 920,000.00 460,000.00
~
indicated
!
Not
~
ROCS-07-03078 9,600,000 TRC 4,800,000.00 480,000.00 960,000.00 480,000.00
I indicated
i
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In OMB-C-C-14-0018 (FIO VS.
, I ,'
Rodolfo G.Plaia et.al.) and0B-q-
C-13.;:6319 (NBI vs. Rodolfo 6.
,1,
Plaza,' et.al.) The following
tr ansactions occur r ed with the Office
of Congr essman RodolfoG. PlaZa
("Cor ig. Plaza"):
, 156. In SARO #D-09-04013, the amount is Five Million
Pesos;(Php 5,000,000.00) andt~eagency isNLDC. '
'157. The computation rfthe, commission is her ein pr ovided,
towit:
Per centage Amount
CongoPlaza
50~
Php 2,500,000.00
Alexis Sevidal
5%1
Php 225,000.00
I
158. The full payment to CongoPlaza was per sonally picked
.
"
up by himmcash at Dlscove
f
SUItes.Themoney for Alexis Sevidal
was deliver ed by mt staff Ev lynDeLeon at his office intheNLDC
at One Cor por ate Plaza Ar naiz Avenue Makati, after the clear ing of
, I I
the check issued by the GOC
I
": ,
: 159. InSAllO #ROOS-09~U3030,theamount isTwoMillion
Five iIundr ed Thousand PesJs (php 2,500 000 00) and the agency is
NLD
, ,
C.
.:'
"
~160.
T~e clmputatiQ[
of commission is her ein pr ovided, to
,
Wit:
1
Per centage Amount
CongoPlaza
I
SOfa Php 1,250,000.00
Alexis Sevidal
5~
Php 118,750.00
I
I
I
"
-~,
. ~:
161. The cash was de~iver ed at the r esidence of CongoPlaza in
#71 Tagbilar an St., Alabang \llillS by my staff dr iver John Raymond
De Asis, The cash was Place1 in asealed b.r own envelope. Later in the
evening I r eceived a call fr om Congr essman Plaza confir ming his
r eceipt. The money for Ale~~ Sevidal was deliver ed by my. staff
Evelyn De Leon to his offic~mthe NLDCat One Cor por ate Plaza,
Ar naiz Avenue, Makati, afte I the' clear ing of the check issued by the
GOCC.
. .,:;,162: In SARO #'OCS-~9-06339. the amount is Seven
Million FIve Hundr ed Thousand Pesos (php 7,500,000.00) and the
agency isNLDC.
163. :~~ computatior of c~mmiSSionis pr ovided her ein. to
I
Per centage Amount
CongoPlaza I
59%
:
Php 3,750,000.00
..Alexis Sevidal
5'f
Php 356,250.00
~.164 Th ful 11 \ C PI deoosi d' hl
I e payment to .ong. aza was eposite In IS
Metr obank account. The cas~for Alexis Sevidalwas deliver ed by my
staff Evely~De Leon at hi1~ffice in the. NLDC at One ~or por ate
Plaza, Amaiz Avenue, Makati, upon clear mg of the check Issued by
the GOCC.
. .
165. Payments to ~ongr essman Rodolfo Plaza ar e either
pickedup by himIinmy o,ce inthe Discover y Suites, deliver ed to
his r esidence in #r Tagbilar an st., Alabang Hills by my staff dr iver
John Raymond De Asis J deposited to -his per sonal metr obank
account. .The money for 4exii S,evidal was deliver ed by my staff
Evelyn De Leon ~t his office ir i the NLDC at One Cor por ate Plaza
Ar naiz Avenue Jakati. up?n clear ing of the check issued by the
.GOCC. Payments to Allan avellana lmd Rhoda Mendoza ar e either
". ,
\\
" ". ~.,
.:. ".
picked up by Rhoda Mendoza in my office or she is met up by my
staff somewher e inor near her officebuilding inthePhilippine Stock
ExchangeOr tigas.
,-;'
166. For tr ansactions ith Congr essman Rodolfo G. Plaza.
Thecomputation of thecommlssi~nis her einpr ovided. towit:
44
~
ALEX IS ALLAN
I
-.....
- --' ,
JAVELLANA' .
JUlQI)A
I
Rodolfo Ompong SEVIDAL
SARONo. Date Amount Agency MENDOZA
Plaza 50% (NLDC)S% (NABCOR)
' . (NABCOR) 5%
AFlERTAX 10%
ROCS-08-00388 1 1 1 0 / 0 8 5,500,000 NABCOR 2,750,000.00 550,000.00 275,000.00 .
I
ROCS-08-05176 6/ 1 0 / 0 8 7,000,000 NABCOR 3,500,000.00 700,000.00 350,000.00 !
~
D-09-04013 6/ 4/ 0 9 5,000,000 NLDC 2,500,000.00 225,000.00 ~
,~
ROC&1l9dl3.030 --5L12/1J~ -2,5,nQ,O_~ NLDC 1,250.000.00 123,750.00
~
~
ROCS-09-06339 8/ 2 0 / 0 9 7,500,000 NLDC 3,750,000.00 356,250.00 i
,
~
-. )-''!;'~'-','.. ,,:~ .: ~
... . ~' ' ' ' ' ' ;' ' : ' ' ' ".
,
,
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In OMB-C-C-14-0017 (FIO vs.
Rizalina Seachon-Lanete) andlOMB-
.C-C-13-020 (NBI vs.~alina
Seachon-Lanete, et.al.) The following
tr ansactions occur r ed with th9 Office
of Congr ess woman Rizalina S achon-
Lanete ("C()ng. Lanete"):
. 167. In lieu of cash advances, Congr esswoman Lanete
r equests additional ~luPPliesto be distr ibuted to h~r constituents in the
3rd dis~ict of Masl!ate instear . Al;fX iSs~vidal got 5% commission
amounting to Four Hu~d~edl seventy. Flve. Thou~and Pesos (Php
475,O()O.OO). The commission of Alexis deliver ed 10per son by my
staff Evelyn de Leon at his ~ffice in the NLDC at One Cor por ate
Plaza, Ar naiz avenu I Makati, upon clear ing of the check issued by the
GOCC.
168. For tr a s~ctions I"Co~gr ~ss~oman. Rizal~a Seacho~-
Lanete. The coJIlPubtlOn oft ecommission ISher em pr ovided, to Wlt:~
:;.
"~, ~
I
ALEX IS
I
ANTONIO DENNlS ALLAN RHODA
~
SEVlDAL
.~-: , .-, ...
"
SARONo. Date Amount Ageney ORTIZlMAYA CUNANAN JAVELLANA MENDOZA
(NLDC)5%
SANTOS (TRC) 10% (fRC)S% (SABCOR) 100/. (NABCOR)5%
AFTER TAX
ROCS-07-00699
1 1 1 6/ 0 7 5,000,000 TRC 500,000.00 250,000.00 i
I
-- -- I
ROCS-07-02116
2/7/07 5,000,000 TRC 500,000.00 250,000.00 i
i
ROCS-07..(J2964
2 / 9/ 0 7 15,000,000 TRC 1,500,000.00 . 750,000.00'
I
I
---.ROC&o"L-012U_
- 9f 1 .' 5- 1 0 7 - ----'--509,000.00 " .
I
-5,000;600- -me zse.ooo.oo
I
,
ROCS-07-0936S
.1 2 1 7 J 0 7
5,000,000 TRC 500,00().00 250,000.00
~
~
.i
, " ~..
,.ROCS..(JS-OO123 .
.. 1 1 9/ 0 8 . . '"!RC'::': ...
._ ....
. 900,000:00 450,000;00 .
, . .:1:..:: ... _~_'.:-~ . :-:...... . ..
~
9,000,000
. ROCS-()S-()OI24
1 1 9/ 0 8 1.,000,000
;
._-
I
ROCS-OS-03727
5/7/08 15,000,000 NABCOR 1,500,000.00 750,000.00
,
/.
~.
ROCS-OS-07174
1 0 / 2 / 0 8 13,290,000 NABCOR 1,329,000.00 664,500.00
J '
I
ROCS-()8-()7175
1 0 / 2 / 0 8 1,710,000
I,
---
I
~

ROCS-09-04IS2
6/ 1 8/ 0 9 10,000,000 NABCOR
i
t
G-09-07620
1 0 / 1 4/ 0 9
~
10,000,000 NLDC 475,500.00
~
s
~
ROCS-09-0 1695
..
~
4/ 1 3 / 0 9 20,000,000 NLDC 950,000.00
-
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In OMB-C-C-14-0007 (~IO vs.
Constantino Jaraula et.al.) anti 01\1B-
, I
C-C-13-0317 (NB I vs. Constantino
Jaraula, et.al.) The following
transactions' occurred with t~eOffice
of Congressman Constantino Jar aula
("Cong. Jar aula"):
169. In SARO # ROCS-07:':00580, the amount is Ten Million
, I ' "
Pesos (Php 10,000,000.00) and the agency is TRC.' ,
170. The COffiPutatil of the commission is her ein pr ovided,
towi t:
I
I Percentage Amount
, Cong.Jar aula , 5,% .,
Php 5,000,000.00
Antonio Or tiz 10% Php 960,000.00
I
Dennis Cunrnan
st
o
l.;
Php 480,000.00
I
171. I .Lr ecall thedetails dur ingthetimewhenhepicked
u~~s advan~s +heisth, oneper sonally getting~s :",mmissi<>n"
Discovery SUites ind was,hfded by me. The COmnlISSIOn of Antomo
Ortiz was picked up by tnself in Pancake House in Malayan
Building in Ortigas. Dennis I.Cunan~was met up by my nephew John
Lim in the parkinJ lot of Metr owalk in Ortigas.
I ' ,
.. 172. For t.sactiQDS with Congr essman Constantino Jar aula.
Th
. f'th r
h
, ided.to wi ~.,.....-
ecomputationr t ecomr mssionIS er empr ovi e 10 WlI: ' -0
SARONo. Amount Agency /.Congressman Constantino
Jarau)a 50%
ANTONIO ORTIZIMAYA
.> .' . -
SANTOS (TRC) 10%
DENNIS CUNANAN
(TRC) 5~1o
ROCS-07- /10,000,000/ TRC /5,000,000.00
00580
1,000,000.00 500,000.00
ROCS-07- /10,000,000/ TRC /5,000,000.00
00861
1,000,000.00 500,000.00
(~ ."
ROCS-07~
.' ,05450 ,
i
,
~
,,~
10,000,000I TRC
n; "
5,000,000.00
. 1,00l>-;-Olr o-:-O-O -soo;ooo:)} o
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In OMB-C-C-14-0003 (lfIOv~.
Edgar Valdez) and OMB-C-C~13-
0314 (NBJ vs. Edgar Valdd1z,et.al.)
The following tr ansactions r ccur r ed
with the Office of conr essman
Valdez ("Cong. Valdez"):
: 173. InSARO #ROfS-09-04258, the amount is Ten Million
Pesos (php 10,0001000.00) ar the agency isNLDC.
174. In lieu of cashadvances, Congr essman Valdez r equested
addit~Ona1 supplies to be ~str i~~d to the ~r ovince of Cotabato,
Alexis Sevidal got 5% COFisslon amounting ,to Four Hundr ed
Seventy Five Thousand Pesos (Php 475,000.00). The commission of
Alexisdeliver ed i~per son bf my staff Evelyn de Leon at his office in
the NLDC at One Cor por ate Plaza Amaiz Avenue Makati, upon
clear ing of the chTk issued i.r the GOCC. .
. 17~. For Jiansacti~nj wi~hCon~r essw~manEdg~Valdez. Thr -e
computation of thecommiss onIS her einpr ovided, toWIt:
, '
.. .'
. '
f : , _
"!' ".
ALEX IS ANTONIO ALLAN RHODA
"', DENNIS
....- "SEVIDALORTIZlMAYA . JAVELLANA ,MENDOZA . - .-
SARO No. Date Amount Agency CUNANAN,'
. (NLDC) 5% SANTOS(TRC) (NABCOR) (NABCOR)
(TRC)5%
AFTER TAX 10% . 100/0 5%
ROCS-07- 2 / 1 6/ 0 7 __ 15,000,000 TRC 1,500,000.00 750,000.00
03546
ROCS 07- 1 0 / 1 6/ 0 7 5,000,000TRC 500,000.00 250,000.00
- - - - - - - - - - I - e14~7~- - _ , - - - - - - - - - - - i _ ~- - ~- - - - I - - - - - - - - - I - ~- - ~- I - - - - - ~- - - - I - - - - - - - - - I - - - - - - - - - ~- - - - - - - - ~- - - - - - - ~- - - - - - - - -
ROCS-08- 10/9/08 12,000,000 NABCOR 1,200,000.00 600,000.00
';"-i.". 08006,- ... .i' . _ ,' ,. _"'
ROCS 08- 5/7/08 10,000,000 NABCOR 1,000,000.00 500,000.00 :
,.
03923 "
n
ROCS 09- 41 1 4/ 0 9 - 15,000,000 NLDC 712,500.00 f
m~ . I
,
ROCS 09- 6/25/09 15.000,000 NLDC 712,500.00 / 11.. ~.I .
04258 ( ~ ~
7 f !
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176. As stated, I ame eciutingthis affidavit to shed light on
thefacts and cir cumstanceJ s 0u~ding the PDAF and Malampaya
. \ I .
Fund seams involved in tlie ase$:pending befor e this Honor able
Officeandto suppor t my r e~u st to beutilized as statewitness andto
be gr anted immunity fr omcr i mal pr osecution in accor dance with
Section 17ofR.A. 6770. .j
.. 177. I har also a ac ed her ewith some of the documents
whichI was abletor etr ieve ughthe helpof my staff, towit:
Annex 1~- Metr o Check with No. 2550388964 issued
infavor rfRuby Th
Aimex B - Metr o~ Check with No. 0354123445 issued
infavor bf Car l D1m ieLabayen
Annex C - Metr o~ Check with No. 0733638728 issued
infavor OfRosem: V. Tuazon
Annex D- Metr o~a Check with No. 0354123459 issued
infavor ~f Dennis C nanan,
\
Other pieces of document evidence ar e still being r etr ieved and
will besubmittedwhenavai a le,
s 178. Honor able Omb dsman, please under stand my situation.
I amonly an or dinar y bus~ sswoman who wanted to ear n for my
family. I had all the intentid to:comply with all ther equir ements of
thelaw. Inmy inter est tobe letohavebusiness, I only complied of
,
..
;,.
52
what is r equir ed of me by the gover nment officials I was dealing with.
I am: not capable to do subhacomPlicated scheme to be the
master mind of all these.
i
.179. I amaIr other and awife for emost. I just wanted to make
a living for my far 1.ily. Thusl as a, mother , I am appealing for the
exclusion of my childr en )ames: Chr istopher Napoles and Jo
Chr istine Napoles in the abo~e-r hentioned Complaints .. My childr en
. had'no knowledge, par ticipatJonand involvement whatsoever in the
subject cases.
180. Evelyn De Leonl John Raymond De Asis and Ronald
John Lim and Eulogio Rodr iguez ar e also r equesting to be utilized as
state witnesses andi be gr anter immunity fr om pr osecution. They too
ar e willing to execute their or affidavit in suppor t of the r equest,
181. I am executing this Affidavit to attest to the tr uth of the
\. .
for egoing slatemel ;
. IN WITNESS WHEREOF, I have her eunto set my hand and
affIX ed my signatur e this Hly 1~1614 day of May, 2014 in Makati
City. I .
~~1SP~1~~~ .
~~?Rl.~C V . RI V EM
SUBSCRmED ANDswonx to befor e me this . day
of MAY 1 2 201~1 2014 at CITY OF MAK ATI City affiant
exhibited to me her P ssper t No. EB 8041872 issued at
on ll. .
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Doe. No. L/ 1~
Page. No. q ( '
Book No. -,-".r=--_
Ser ies of2014.
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ATTY. LANEE S. CUIDAVID
CollllllilllioDNo. M19S
Notar y Publie fOf MaItaII City
Until Dccembor 31. 2 0 1 S
7" Floor SQ\Ir ~~ Tower
100 Toll1csillu S\, cor HVDel' COsta S\,
.. Salccdo Villauc. Makali City .227
Attomey', RoDNQ.oIOl47
PTR No, 9794150J0loOl2014Il'11sig City
IFII' LR /'In.026~SIOI..o3.()2IPasig City
MCU; Compliance No.lV.ooo711l1UlHI~qI2
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